how do I combine data from different foam and spring suppliers in one passport

One passport, multiple suppliers as source

A mattress usually consists of components from different suppliers — foam from one, springs from another, cover and finishing possibly from a third — and that data comes together in one digital product passport per mattress, not in separate passports per component. The manufacturer placing the mattress on the market, or the importer for mattresses from outside the EU, is the party that brings together all the data from those supply chains and prepares it for the passport. In practical terms, this means that the same type of information is needed from each supplier regarding their part of the product, and that information is collected in a fixed location before the passport is compiled.

For whom this applies and where the boundary lies

This concerns the situation in which a mattress is built from materials or components that come from different companies — foam blocks, spring systems, covers, adjustable mechanisms. The party that assembles the mattress and sells it under its own name or brand bears responsibility for the complete passport, even if that party has not produced the foam itself or manufactured a spring. It does not apply to suppliers who do not place a mattress on the market themselves: a foam manufacturer that only supplies foam blocks to a mattress maker does not place a mattress on the market itself and is therefore not subject to the passport obligation, although that foam manufacturer is the party that must provide the correct data about its material. This distinction between who makes the passport and who supplies the building blocks for it is precisely what Article 38 of the ESPR (Regulation (EU) 2024/1781) addresses: actors in the supply chain are required to provide the data necessary for compliance, without thereby becoming responsible for the passport as a whole.

When this really comes into play

When the product passport for mattresses is exactly required remains uncertain — When will the product passport become mandatory for mattresses? goes into further detail. Until the relevant delegated act is published, there is no legal obligation to collect and bundle this data per mattress. However, this is the right time to start anyway, because the question "how do I combine data from multiple suppliers" is precisely the type of process that requires time to get in order — suppliers need to know what is being asked of them, data must come in a comparable format, and that is not something you sort out in a week. Anyone who now already specifies which foam type, which spring type and which composition is in a mattress is better positioned once the obligation becomes concrete.

How to approach this in practice

The first step is to establish which components of the mattress come from which supplier, and what data for each of those components is relevant for the passport — think of material composition, origin, and any chemical substances. Which data must I request from my mattress supplier? describes what that question concretely amounts to. Subsequently, it is advisable not to ask this question on a non-binding basis but to fix it in agreements with the supplier, so that it is clear who supplies which data, in what form and at what time — How do I document the supply of passport data in my purchasing contract? goes into further detail. After that, it is important to check the incoming data from the different suppliers before it ends up in the passport, because a passport is only reliable if the underlying data is too — see How do I check whether my supplier's data is correct?When data from a supplier does not arrive or is incomplete, you will find in My supplier does not provide the data — what can I do? a description of the options. And when a foam or spring supplier is later changed, it is important that the passport remains accurate; does the product passport remain accurate if I switch to a different mattress material supplier addresses precisely that situation.

The legal basis: Article 38 and Article 10 of the ESPR

That a mattress with multiple suppliers is nevertheless described in a single passport follows from the way in which the ESPR allocates roles. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements that the digital product passport as a whole must meet — the passport belongs to the product as placed on the market, not to the individual components. Article 38 of the ESPR requires actors in the supply chain to provide the information needed to meet those requirements, which forms the basis for requesting data from foam and spring suppliers. And for mattresses imported from outside the EU, Article 29 of the ESPR imposes comparable obligations on the importer, who is then in the position of having to collect the data of the manufacturer outside the EU — What does the product passport mean if I import mattresses from outside the EU? describes that situation further.

If you are already working with multiple foam and spring suppliers, it is best to start by drawing up an overview of which supplier provides which component and what data belongs with it — that overview is the basis for every passport that will later be compiled, regardless of the precise date on which the obligation takes effect.